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was allegedly later asked by Epstein to provide erotic massage. In 2009, lawyers preparing a case against Epstein meanwhile took a deposition from Alfredo Rodriguez, Epstein's former housekeeper. In it, he claimed that Ms Maxwell kept an office under the stairs in the Palm Beach property, saying her computer con
e stairs in the Palm Beach property, saying her computer contained a list of girls who came to give massages there, along with their phone numbers. Rodriguez further claimed that Maxwell kept nude pictures of some of these girls on the device. He believed these photos had been taken without the young wome
her audience to become supporters of the non-profit organisation. She explained how Terramar which boasts her friends Sir Richard Branson and Lord Mandelson as supporters runs a jazzy website which carries educational literature, petitions and fund-raising tools devoted to campaigning for marine conserva
s allegedly later asked by Epstein to provide erotic massage. In 2009, lawyers preparing a case against Epstein meanwhile took a deposition from Alfredo Rodriguez, Epstein's former housekeeper. In it, he claimed that Ms Maxwell kept an office under the stairs in the Palm Beach property, saying her computer c
stairs in the Palm Beach property, saying her computer contained a list of girls who came to give massages there, along with their phone numbers. Rodriguez further claimed that Maxwell kept nude pictures of some of these girls on the device. He believed these photos had been taken without the young wom
r audience to become supporters of the non-profit organisation. She explained how Terramar which boasts her friends Sir Richard Branson and Lord Mandelson as supporters runs a jazzy website which carries educational literature, petitions and fund-raising tools devoted to campaigning for marine conser
d, Ste. 1200 Ft. Lauderdale, FL 33301 s/ Brenda Rodriguez Brenda Rodriguez 24 EFTA00595611
25 ii EFTA00595584 Case 1:15-cv-07433-RWS Document 15 Filed 12/01/15 Page 3 of 29 Cases Abrams v. United States, 250 U.S. 616, 630 (1919) 17 Adelson v. Harris, 973 F. Supp.2d 467, 477 (S.D.N.Y. 2013) 7 Armstrong v. Simon & Schuster, Inc., 625 N.Y.S.2d 477 (1995) 7 Ashcroft v. lqbal, 129 S. Ct.
went through these, it 19 seems to me that we have dealt with number 679, 716, in 20 connection with 683, 742, and 774. That deals with the 21 Rodriguez, we call it the unauthenticated hearsay document from 22 a suspect source. They call it the black book. I think the 23 Court heard argument about
ork street 20 that, "I am referring to the statement that we made." As we 21 set forth in our summary judgment brief, this Court's ruling in 22 Adelson v. Harris is directly on point, that a mere reference 23 to another writing that contains defamatory statements does not 24 constitute an actiona
onor, when I went through these, it seems to me that we have dealt with number 679, 716, in connection with 683, 742, and 774. That deals with the Rodriguez, we call it the unauthenticated hearsay document from a suspect source. They call it the black book. I think the Court heard argument about all of
t on a New York street that, "I am referring to the statement that we made." As we set forth in our summary judgment brief, this Court's ruling in Adelson v. Harris is directly on point, that a mere reference to another writing that contains defamatory statements does not constitute an actionable repe
tion with 683, 742, and 774. That deals with the Rodriguez, we call it the unauthenticated hearsay document
t on a New York street that, "I am referring to the statement that we made." As we set forth in our summary judgment brief, this Court's ruling in Adelson v. Harris is directly on point, that a mere reference to another writing that contains defamatory statements does not constitute an actionable repe
Entities connected to both Alfredo Rodriguez and Peter Mandelson

Jeffrey Epstein
PERSON
Richard Kahn
PERSON
Martha Stewart
PERSON
Marc Rich
PERSONDarren Indyke
PERSON
Bella Klein
PERSON
Ghislaine Maxwell
PERSON
Lesley Groff
PERSON
Prince Andrew
PERSON
George Mitchell
PERSON
Carlos
PERSONLeon Black
PERSON
Donald Trump
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
NEW YORK NY
LOCATION
Department of Justice
ORGANIZATION